Bryant v Madison Management Services, LLC, et al

Filing 41

ORDER granting 40 Stipulation to Extend Time. Discovery due by 8/5/2021. Motions due by 9/15/2021. Proposed Joint Pretrial Order due by 10/16/2021. Settlement conference shall be set by separate order. Signed by Magistrate Judge Elayna J. Youchah on 2/25/2021. (Copies have been distributed pursuant to the NEF - DRS) Modified filed date on 2/26/2021 (DRS).

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George Haines, Esq.
Nevada Bar No. 9411
FREEDOM LAW FIRM
8985 S. Eastern Avenue, Ste. 350
Beltway Corporate Center
Las Vegas, NV 89123
Telephone:[phone]
[e-mail]
Counsel for Plaintiff Lisa A. Bryant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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:
:
:
:
Plaintiff,
:
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v.
:
MADISON MANAGEMENT SERVICES, :
LLC, and WALDMAN & PORRAS, PLLC, :
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:
Defendants.
:
:
LISA A. BRYANT,

Case No.: 2:20-cv-00594-JAD-EJY

[PROPOSED] STIPULATION AND
ORDER TO STAY DISCOVERY AND
SCHEDULE SETTLEMENT
CONFERENCE
[FIRST REQUEST]

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Pursuant to Local Rule 16-5, Plaintiff, Lisa Bryant, and Defendants, Madison Management

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Services, LLC, and Waldman & Porras, PLLC, (collectively known as the “Parties) by and

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through their attorneys, hereby stipulate to stay all discovery deadlines and other deadlines in the

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February 1, 2021 Scheduling Order (ECF No. 39) for 60 days pending mediation and settlement

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discussions.

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1.

Completed Discovery.

The parties have exchanged initial disclosures. Parties have served written discovery.
2.

Remaining Discovery.

Written discovery responses from Plaintiff and the parties’ depositions.

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3. Good Cause.

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The parties believe that this case is ripe for mediation at this time and are seeking a 60-day

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stay all discovery deadlines and other deadlines. This stipulation is made in good faith, is not

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interposed for delay, and is not filed for an improper purpose. Furthermore, a trial date has not

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been set at this time.

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4. Current Discovery Deadlines.
 Discovery Cutoff: June 5, 2021

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 Deadline to Amend Pleadings: March 17, 2021

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 Deadline to Disclose Initial Expert Disclosures: April 16, 2021

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 Deadline to Disclose Rebuttal Expert Disclosures: May 17, 2021

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 Dispositive Motion Deadline: July 15, 2021

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 Joint Proposed Pretrial Order: August 16, 2021

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5.

Proposed Discovery Deadlines.

 Discovery Cutoff: August 5, 2021
 Deadline to Amend Pleadings: May 17, 2021
 Deadline to Disclose Initial Expert Disclosures: June 16, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: July 17, 2021
 Dispositive Motion Deadline: September 15, 2021
 Joint Proposed Pretrial Order: October 16, 2021
WHEREAS, no prejudice will occur to this Court or the Parties if granted, good cause
supports this request to extend discovery;
NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS
HEREBY STIPULATED AND AGREED, by and between the Parties as follows:
The February 1, 2021 Scheduling Order shall be amended as follows:
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 Discovery Cutoff: August 5, 2021
 Deadline to Amend Pleadings: May 17, 2021
 Deadline to Disclose Initial Expert Disclosures: June 16, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: July 17, 2021
 Dispositive Motion Deadline: September 15, 2021
 Joint Proposed Pretrial Order: October 16, 2021

NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS
HEREBY STIPULATED AND AGREED, by and between the Parties that this matter shall be

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scheduled for Court Mediation/Settlement Conference on a future date selected by the Court that

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is at least 30-days from the filing of this Stipulation and Order to Stay Discovery and Schedule

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Settlement Conference.

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IT IS SO STIPULATED.
DATED: February 22, 2021

DATED: February 22, 2021

FREEDOM LAW FIRM, LLC

WALDMAN & PORRAS, PLLC

By: /s/ George Haines
GEORGE HAINES, ESQ.
Nevada Bar No.: 9411
8985 S. Eastern Ave., Suite 350
Las Vegas, NV 89123
Attorney for Plaintiff
LISA BRYANT

By: /s/ Nicholas M. Porras
NICOLAS M. PORRAS, ESQ.
Nevada Bar No.: 12849
201 West Liberty Street, Suite 207
Reno, NV 89501
Attorney for Defendants
MADISON MANAGEMENT SERVICES,
LLC, AND PORRAS, PLLC

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ORDER GRANTING
STIPULATION TO EXTEND DISCOVERY
In consideration of the parties’ stipulation and good cause showing, IT IS ORDERED
THAT the February 1, 2021 Scheduling Order shall be amended as follows:
 Discovery Cutoff: August 5, 2021;
 Deadline to Amend Pleadings: May 17, 2021;
 Deadline to Disclose Initial Expert Disclosures: June 16, 2021;
 Deadline to Disclose Rebuttal Expert Disclosures: July 17, 2021;
 Dispositive Motion Deadline: September 15, 2021; and
 Joint Proposed Pretrial Order: October 16, 2021.

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IT IS FURTHER ORDERED that t he Cour t will issue a se par at e o r de r
sc h ed u lin g th e settlement c onf e r e nc e .
IT IS SO ORDERED.
________________________________________
UNITED STATES MAGISTRATE JUDGE

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Dated: February 25, 2021

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